Vpp Ssa 1218-0239 Rocis File 4.12.2021

Voluntary Protection Programs (VPP)

OMB Control No. 1218-0239

April 30, 2021

ASUPPORTING STATEMENT FOR THE

THE VOLUNTARY PROTECTION PROGRAMS (VPP)

OFFICE OF MANAGEMENT AND BUDGET (OMB)

CONTROL NO. 1218-0239 (April 2021)

This ICR seeks to extend the authorization of the existing collection of information without change.

1. JUSTIFICATION

1. Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection. Attach a copy of the appropriate section of each statute and regulation mandating or authorizing the collection of information.

The Occupational Safety and Health Administration’s (OSHA) mission is to prevent work-related injuries, illnesses, and deaths. OSHA’s primary means of accomplishing this mission is the promulgation and enforcement of occupational safety and health standards. However, OSHA recognizes that it cannot accomplish its mission solely through the enforcement of such standards, and employs other strategies to accomplish its mission. One of these strategies is to encourage employers to implement comprehensive safety and health management programs.

OSHA’s Voluntary Protection Programs (VPP), a partnership between labor, management, and government, is designed to recognize and promote excellence in safety and health management. Traditionally, OSHA only offered VPP recognition to fixed worksites.

In 2004, OSHA introduced the VPP Corporate and OSHA Challenge as pilot programs, and in 2006, OSHA introduced the Mobile Workforce for Construction pilot program. The VPP Corporate pilot program provided corporations committed to VPP and interested in achieving VPP recognition at facilities throughout their organization with more efficient means to accomplish this goal. The Mobile Workforce for Construction pilot was designed to reach out to smaller employers such as those engaged in specialty contracting where current VPP policies excluded employers who did not have authority for safety and health for the entire worksite. The OSHA Challenge pilot program provides a greater opportunity to eligible employers interested in working with OSHA to create safer and healthier workplaces for their employees.

In 2009, OSHA formalized two of the pilots – Mobile Workforce for Construction and VPP Corporate with the publication of the Revisions to the VPP to Provide Safe and Healthful Working Conditions Federal Register Notice (FRN). OSHA added to its traditional focus on individual VPP fixed worksites (site-based) by adding two new ways to participate: VPP Mobile Workforce and VPP Corporate. These revisions to the FRN clarified the multiple participation options now available within VPP. OSHA Challenge remains a cooperative program.

Participation in VPP is strictly voluntary, and does not diminish existing employer and employee rights and responsibilities under the Occupational Safety and Health Act (OSH Act). In particular, OSHA does not intend to increase the liability of any party in an approved VPP site. Employees or any representatives of employees taking part in an OSHA-approved VPP safety and health management program are not assuming the employer's statutory or common law responsibilities for providing safe and healthful workplaces, or undertaking in any way to guarantee a safe and healthful work environment.

In order to participate in the VPP, OSHA requires an applicant to submit an application and an annual self-evaluation containing a detailed description of its safety and health management programs. OSHA needs this information to conduct a preliminary analysis of the worksite’s programs, and to make a preliminary determination regarding the worksite’s qualifications for VPP. Lacking this information, OSHA would consume thousands of person-hours conducting onsite evaluations at worksites that are not ready to qualify for the VPP.

In order to be recognized as a VPP worksite, applicants must adhere to the VPP programmatic requirements. VPP Star is the most prestigious recognition and has the most rigorous requirements; only sites with the most exemplary safety and health management programs achieve Star status. VPP Merit sites, meanwhile, have good safety and health management programs, but must take additional steps to reach VPP Star status. OSHA is currently examining the practical utility of the Merit program. The Federal Register Notice that established VPP as a program (47 FR 29025, July 2, 1982) provided the benefit that VPP worksites be removed from OSHA’s general schedule programmed inspection list. All VPP worksites are removed from programmed inspection lists for the duration of their participation. Un-programmed inspections occur at VPP worksites in response to all referrals, formal complaints, fatalities, and catastrophes.

Site-Based

The Site-based way to participate continues VPP’s traditional acceptance of applications from fixed worksites and some long-term construction sites. Within site-based VPP participation, OSHA accepts VPP applications from the owners and site officials who control site operations and have ultimate responsibility for assuring safe and healthful working conditions of: Private-sector fixed worksites in general industry and the maritime industry; Construction worksites/ projects that will have been in operation for at least 12 months at projected time of approval and that expect to continue in operation for at least an additional 12 months; Federal-sector fixed worksites, and certain resident contractors.

VPP Corporate

The VPP Corporate way to participate is intended for corporations who are committed to achieving VPP approval for multiple specified individual sites within their organization. The corporation must utilize well-established, standardized safety and health management programs at all participating sites, employ a prescreening process to ensure that their sites have effectively implemented the programs, addressed site-specific hazards, and satisfied the VPP requirements. Organizations who achieve VPP Corporate status are able to utilize streamlined application and onsite evaluation processes to bring into VPP individual sites.

OSHA is revising the VPP Corporate policy and a new pilot program for VPP Corporate is being developed and will be added upon agency approval.

Over the past few years, interest in the VPP Corporate program has dwindled. OSHA is reviewing the practical utility of this program.

Mobile Workforce

The Mobile Workforce way to participate is intended to create greater opportunity for employers and employees in industries that did not qualify for the traditional VPP site-based way to participate. Mobile workforce participation is intended for: 1) applicants/participants whose employees move physically from one work project to another; and 2) applicants/participants who employees work as resident contractors at two or more fixed locations.

OSHA Challenge

OSHA Challenge is designed to reach and guide employers and companies in all major industry groups who are strongly committed to improving their safety and health management programs and possibly pursuing recognition in the VPP. OSHA Challenge provides participants with a guide or roadmap to improve performance in managing safety and health at their worksites. Over the past few years, interest in OSHA Challenge begin to dwindle. In 2020, OSHA established a working group to review the practical utility of this program.

Special Government Employee (SGE) Program

The Special Government Employee (SGE) Program supports the VPP and provides the opportunity for safety and health professionals employed at approved VPP sites to assist and participate with OSHA on VPP onsite evaluations. Prior to participating on an onsite evaluation, the eligible SGE must apply to and receive from OSHA the formal SGE training class. Upon successful completion of the training course, the SGE may volunteer to participate on a VPP onsite evaluation team.

In 2014, Challenge Administrators deemed the use of Challenge Coordinators assistance unnecessary in managing Challenge participants; therefore, there is no longer a need for Challenge Coordinators’ applications.

In 2015, OSHA modified the SGE policies & procedures for SGE applicants who wish to extend their three-year initial term or renew their term as an SGE to indicate on the SGE Eligibility Information Sheet a minimum of three (3) qualifying activities they were involved in during their previous three-year term of service.

In 2008, OSHA modified the VPP procedures for all applicants/participants subject to OSHA standards 29 CFR 1910.119 and 1926.64 (Process Safety Management (PSM)). The standards cover all employers who either use or produce highly hazardous chemicals exceeding specified limits. The procedural modifications affected the applications, onsite evaluations, and annual participant self-evaluations process for these applicants/participants.

In 2020, OSHA placed the VPP Corporate way to participate on hold see (CSP 03-01-005, dated 1/30/2020).

2. Indicate how, by whom, and for what purpose the information is to be used. Except for a new collection, indicate the actual use the agency has made of the information received from the current collection.

Site-based and Mobile Workforce

OSHA’s Regional Office personnel use the initial VPP application to: 1) conduct a preliminary analysis of the applicant’s safety and health management programs, and 2) make a preliminary determination regarding the applicant’s qualifications for VPP. Once accepted, the VPP onsite evaluation team, prior to conducting a VPP onsite evaluation, reviews the application. If the applicant is approved for participation, federal personnel and SGEs will use the application and subsequent annual evaluations to 1) justify continued participation in the program, 2) evaluate program performance, and 3) as models of effective safety and health management.

VPP Corporate

OSHA’s Regional and National Office personnel use the initial VPP Corporate application to: 1) conduct a preliminary analysis of the applicant’s safety and health management programs, and 2) make a preliminary determination regarding the applicant’s qualifications for participation. If the corporation is approved for participation, federal personnel use the application and subsequent annual evaluations to justify continued participation in the program and evaluate program performance.

OSHA Challenge

OSHA National Office personnel use the initial A Challenge administrator application will indicate that the administrator has knowledge of safety and health management systems and the resources to review Challenge candidates’ applications whereas a Challenge candidate’s application indicates that they have a need to develop a safety and management system to reduce injuries illnesses at their worksites. Challenge Administrators application: 1) conduct a preliminary analysis of the applicant’s knowledge of safety and health management programs; and 2) make a determination regarding the applicant’s qualifications to become a Challenge Administrator. Once a Challenge Administrator is approved, the Administrator will review each challenge participant’s application/annual submissions to ensure that all necessary information is provided, prior to forwarding to OSHA’s National Office for acceptance and analysis.

An OSHA Challenge Candidate is an employer that has elected to submit a Challenge

application to a Challenge Administrator for submission to OSHA. After the Challenge administrator approves the Challenge candidate application OSHA’s Directorate of Cooperative and State Programs reviews and approves Candidate packages; upon vetting by the Region where the candidate is located. The employer remains a candidate until receiving notification from OSHA that it has been accepted into OSHA Challenge as a participant.

The Administrators submit annual reports to OSHA on the progress made by their sponsored participants. The annual reports must contain, as a minimum, summary of annual rates by participant; summary of hazards identified and corrected by participant; and summary of leading indicators by participant.

SGE Program

OSHA’s National Office personnel use the information submitted by the SGE applicants to ensure that individuals are qualified to serve, arrange for participation at VPP onsite evaluations, and inform participants of their status in the program. Specifically, the resume or OMB Control Number 3206-0219 expires 4/30/2021 the Optional Application for Federal Employment (OF 612) is used to ensure that the SGE applicant meets specific conditions and requirements, and OMB Control Number 3209-0006 the Confidential Financial Disclosure Report (OGE Form 450) Expires 11/31/2021is used to ensure that SGEs do not participate on onsite evaluations at worksites where there might be a conflict of interest.

3. Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological techniques, or other forms of information technology, e.g. permitting electronic submission of responses, and the basis for the decision for adapting this means of collection. Also, describe any consideration of using information technology to reduce burden.

OSHA welcomes the electronic submission of VPP documents where such technology is available. Some VPP documents require signatures and must be submitted in hard copy until electronic signature (e-signature) is made available throughout the Department and/or Agency systems.

4. Describe efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use for the purposes described in Item A.2 above.

The VPP application and annual self-evaluation is applicant/participant specific, and is not requested or collected by OSHA in any other circumstances. In instances where OSHA regulations require employers to maintain written programs, this information may be used to satisfy VPP application requirements. The SGE application is applicant-specific, and is not requested or collected by OSHA under any other circumstances.

5. If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden.

Small businesses (i.e., 250 or fewer employees onsite and 500 or fewer employees corporate-wide) account for approximately 4.3% of current VPP participants. Despite the fact that small businesses comprise a relatively small proportion of VPP participants, OSHA is concerned with minimizing their paperwork burden. To that end, OSHA only requires that applicants demonstrate the presence of comprehensive safety and health management programs that are commensurate with their occupational hazardous exposures. Because small businesses typically have a smaller spectrum of hazardous exposures and fewer levels of management, the amount of documentation required to demonstrate the comprehensive safety and health management programs is less than for larger companies. This translates into a smaller paperwork burden for small businesses.

6. Describe the consequence to Federal program or policy activities if the collection is or is not conducted less frequently, and any technical or legal obstacles to reducing the burden.

Not allowing OSHA to collect the information required in VPP applications and annual evaluations for these programs would eliminate the Agency’s ability to accept new participants into the VPP or re-certify current VPP participants for continued participation. This action would deprive VPP participants of the benefits associated with program participation. Forcing OSHA to collect the information less frequently would limit the Agency’s ability to ensure that participants’ sites are maintaining superior safety and health management programs.

Similarly, not allowing OSHA to collect SGEs application information would eliminate the Agency’s ability to accept new individuals into the program, or to reapprove current SGE participants for a new term of service. Requiring OSHA to collect SGE application information less frequently would limit the Agency’s ability to maintain current and accurate information on SGEs and result in a less effective program. Because SGEs are critical for maintaining VPP’s success, a less effective program would deprive OSHA of valuable resources and services provided by the SGEs, limit VPP growth, deny potential and current VPP participants their valuable expertise, and deny individuals the prestige associated with being a SGE.

Not allowing OSHA to collect information required for OSHA Challenge would hinder the Agency’s ability to work with employers committed to improving their safety and health management programs.

7. Explain any special circumstances that would cause an information collection to be conducted in a manner:

• Requiring respondents to report information to the agency more often than quarterly;

• Requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it;

• Requiring respondents to submit more than an original and two copies of any document;

• Requiring respondents to retain records, other than health, medical, government contract, grant-in-aid, or tax records for more than three years;

• In connection with a statistical survey, that is not designed to produce valid and reliable results that can be generalized to the universe of study;

• Requiring the use of statistical data classification that has not been reviewed and approved by OMB;

• That includes a pledge of confidentiality that is not supported by authority established in statute or regulation, that is not supported by disclosure and data security policies that are consistent with the pledge, or which unnecessarily impedes sharing of data with other agencies for compatible confidential use; or

• Requiring respondents to submit proprietary trade secret, or other confidential information unless the agency can demonstrate that it has instituted procedures to protect the information’s confidentiality to the extent permitted by law.

No special circumstances exist that require employers to collect information in the manner or using the procedures specified by this item.

8. If applicable, provide a copy and identify the date and page number of publication in the Federal Register of the agency's notice, required by 5 CFR 1320.8(d), soliciting comments on the information collection prior to submission to OMB. Summarize public comments received in response to that notice and describe actions taken by the agency in response to these comments. Specifically address comments received on cost and hour burden.

Describe efforts to consult with persons outside the agency to obtain their views on the availability of data, frequency of collection, the clarity of instructions and recordkeeping, disclosure, or reporting format (if any), and on the data elements to be recorded, disclosed, or reported.

Consultation with representatives of those from whom information is to be obtained or those who must compile records should occur at least once every 3 years -- even if the collection-of-information activity is the same as in prior periods. There may be circumstances that may preclude consultation in a specific situation. These circumstances should be explained.

As required by the Paperwork Reduction Act of 1995 (44 U.S.C. 3506(c) (2) (A)), OSHA published a notice in the Federal Register on December 23, 2020 (85 FR 84007) soliciting comments on its proposal to extend the Office of Management and Budget’s (OMB) approval of the information collection requirements specified in the Voluntary Protection Programs (VPP) (Docket No. OSHA-2011-0056). This notice was part of a preclearance consultation program that provided interested parties the opportunity to comment on OSHA’s request for an extension by the Office of Management and Budget of a previous approval of the information collection requirement found above. The agency did not receive any comments in response to this notice.

9. Explain any decision to provide any payment or gift to respondents, other than remuneration to contractors or grantees.

The Agency will not provide payments or gifts to the respondents.

10. Describe any assurance of confidentiality provided to respondents and the basis of the assurance in statute, regulation, or agency policy.

Respondents are assured of the confidentiality of their VPP application until it is approved. Confidentiality requirements are outlined in the VPP FRN, the VPP Policies and Procedures Manual, and the SGE Policies and Procedures Manual.

Participants applying for the VPP understand that, if approved to participate into these programs, their application becomes part of the public record. SGEs understand that, if approved to the program, they will be considered active SGEs and may be requested to participate on VPP onsite evaluations. Information collected in the application concerning financial disclosures remains confidential and are not available to the public.

11. Provide additional justification for any questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private. This justification should include the reasons why the agency considers the questions necessary, the specific uses to be made of the information, the explanation to be given to persons from whom the information is requested, and any steps to be taken to obtain their consent.

The information collection requirements do not involve the collection of sensitive information.

12. Provide estimates of the hour burden of the collection of information. The statement should:

• Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated. Unless directed to do so, agencies should not conduct special surveys to obtain information on which to base hour burden estimates. Consultation with a sample (fewer than 10) of potential respondents is desirable. If the hour burden on respondents is expected to vary widely because of differences in activity, size, or complexity, show the range of estimated hour burden, and explain the reasons for the variance. Generally, estimates should not include burden hours for customary and usual business practices.

• If this request for approval covers more than one form, provide separate hour burden estimates for each form.

• Provide estimates of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories. The cost of contracting out or paying outside parties for information collection activities should not be included here. Instead, this cost should be included in Item 13.

Burden-Hour and Cost Determinations

The Agency determined the wage rate from mean hourly wage earnings to represent the cost of employee time. The following hourly wage rate for the relevant occupational category has been derived from the National Occupational Employment and Wage Estimates, published by the Bureau of Labor Statistics May 2020. For the relevant standard occupational classification category, OSHA used the wage rate reported in the Bureau of Labor Statistics, U.S. Department of Labor, Occupational Employment and Wage Statistics (OES), May 2020 National Occupational Employment and Wage Estimates [date accessed: October 2020] (https://www.bls.gov/oes/current/oes_nat.htm). Fringe markup is from the following BLS release: Employer Costs for Employee Compensation news release text; released 10:00 AM (EDT), September 2020 (https://www.bls.gov/news.release/ecec.nr0.htm). BLS reported that for civilian workers, fringe benefits accounted for 30.0 percent of total compensation and wages accounted for the remaining 70.0 percent. To calculate the loaded hourly wage for the occupation, the Agency divided the mean hourly wage rate by 1 minus the fringe benefits.

TABLE 1--WAGE HOUR ESTIMATES
Occupational Title	Standard Occupational Code (SOC)	Mean Hourly Wage Rate (A)	Fringe Benefits (B)	Loaded Hourly Wage Rate (C) = (A)/((1-(B))
First Line Supervisor/ Production Worker	51-1011	$32.12	.300	$45.89

OMB Control Number 3206-0219 for the Optional Application for Federal Employment 0F-612 is still valid.

OMB Control Number 3209-0006 for Confidential Financial Disclosure Report OGE Form 450 is still valid.

The following table summarizes the burden hours and costs associated with each provision of the Regulation that contains a paperwork requirement:

Table 2: Estimated Annualized Respondent Cost and Hour Burden
Information Collection Requirement(s)	Type of Respondent	No. of Respondents	No. of Responses per Respondent	Total No. of Responses	Avg. Burden per Response (In Hrs.)	Total Burden Hours	Avg. Hourly Wage Rate	Total Burden Costs
VPP
VPP Application Types: Site Based Mobile Workforce Corporate	New Applicants for FY18, FY19, and FY20 for a 3-year period	170	1	170	200	34,000	$45.89	$1,560,260.00
VPP Application Supplemental/PSM Questionnaire - A	20% of 170 VPP Applications	34	1	34	40	1,360	$45.89	$62,410.40
PSM Evaluation/Supplemental Questionnaire - B	20% of 2,194 VPP Participants	438.8	1	438.8	20	8,776	$45.89	$402,730.64
VPP Annual Self-Evaluation	2,137 @ beginning of FY21 + 57 average per year	2,194	1	2,194	20	43,880	$45.89	$2,013,653.20
Subtotal	--	--	--	2,836.80	--	88,016	--	$4,039,054.24
Special Government Employees (SGE)
General Eligibility Information Sheet	Average for 3-year FY17, FY18, and FY19; could not use FY20 due to COVID-19	315	0.33 (1 every 3 years)	103.95	10/60	17.33	$45.89	$795.27
Resume	75% of Applicants submit resumes	236	0.33 (1 every 3 years)	77.88	30/60	38.94	$45.89	$1,786.96
Optional Application for Federal Employment OF-612	25% of Applicants submit the OF-612	79	0.33 (1 every 3 years)	26.07	40/60	17.38	$45.89	$797.57
Confidential Financial Disclosure Form (OGE Form 450)	100% of SGE applicants submit the OGE Form 450	1,680	1	1,680	1	1,680	$45.89	$77,095.20
Subtotal	--	--	--	1,887.90	--	1,753.65	--	$80,475.00
OSHA CHALLENGE
Challenge Administrators Application		6	1	6	5	30	$45.89	$1,376.70
Challenge Participant/Candidate Application		12	1	12	10	120	$45.89	$5,506.80
Administrators Annual Summary Report		29	1	29	20	580	$45.89	$26,616.20
Subtotal	--	--	--	47	--	730	--	$33,499.70
GRAND TOTAL	--	--	--	4,772	--	90,500	--	$4,153,029

13. Provide an estimate of the total annual cost burden to respondents or record keepers

resulting from the collection of information. (Do not include the cost of any hour burden shown in Items 12 and 14).

• The cost estimate should be split into two components: (a) a total capital and start-up cost component (annualized over its expected useful life); and (b) a total operation and maintenance and purchase of services component. The estimates should take into account costs associated with generating, maintaining, and disclosing or providing the information. Include descriptions of methods used to estimate major cost factors including system and technology acquisition, expected useful life of capital equipment, the discount rate(s), and the time period over which costs will be incurred. Capital and start-up costs include, among other items, preparations for collecting information such as purchasing computers and software, monitoring, sampling, drilling and testing equipment, and record storage facilities.

• If cost estimates are expected to vary widely, agencies should present ranges of cost burdens and explain the reasons for the variance. The cost of purchasing or contracting out information collection services should be a part of this cost burden estimate. In developing cost burden estimates, agencies may consult with a sample of respondents (fewer than 10), utilize the 60-day pre-OMB submission public comment process and use existing economic or regulatory impact analysis associated with the rulemaking containing the information collection, as appropriate.

• Generally, estimates should not include purchases of equipment or services, or portions thereof, made: (1) prior to October 1, 1995, (2) to achieve a regulatory compliance with requirements not associated with the information collection, (3) for reasons other than to provide information or keep records for the government or (4) as part of customary and usual business or private practices.

The cost determined under Item 12 accounts for the total annual cost burden to respondents or record keepers resulting from these collections of information requirements.

14. Provide estimates of the annualized cost to the Federal Government. Also, provide a description of the method used to estimate cost, which should include quantification of hours, operational expenses (such as equipment, overhead, printing, and support staff), any other expense that would not have been incurred without this collection of information. Agencies also may aggregate cost estimates from Items 12, 13, and 14 into a single table.

The information collection estimates contained in the table below are based on programmatic expertise and experience of Federal personnel in Washington, DC National Office, an average cost estimate of $57.39 per hour of government personnel time (GS-13, Step 6) from salary table 2020-GS. https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/2020/general-schedule/

Table 3: Effects of VPP Information Collection on the Federal Government
Information Collection Requirement(s)	Estimated Number of Respondents (3-year Average)	Frequency of Response	Number of Responses	Estimated Review Time per Document for Federal Employee	Estimated Annual Review Time for Federal Employee	Average Cost Rate Per Hour	Estimated Annual Cost
VPP
VPP Application Types: Site Based Mobile Workforce Corporate	170	1 per year	170	5 hours (GS-13, Step 6)	850	$57.39	$48,781.50
VPP Application Supplemental/PSM Questionnaire – A	34 (20% of VPP Applications)	1 per year	34	4 hours (GS-13, Step 6)	136	$57.39	$7,805.04
PSM Evaluation/Supplemental Questionnaire – B	439 (20% of 2,195 VPP Participants)	1 per year	439	2 hours (GS-13, Step 6)	878	$57.39	$50,388.42
VPP Participation Evaluation Report: Site Based Mobile Workforce Corporate	170	1 per year	170	24 hours (6 hours for each member of a team of 4) (GS-13, Step 6)	4,080	$57.39	$234,151.20
VPP Annual Self-Evaluation	2,194 (2,137 @ beginning of FY21 + 57 average per year)	1 per year	2,194	2 hours (GS-13, Step 6)	4,388	$57.39	$251,827.32
Subtotal	--	--	3,007	--	10,332	--	$592,953.48
Special Government Employees (SGE)
General Eligibility Information Sheet	315	0.33 (1 every 3 years)	103.95	10/60 (GS-13, Step 6)	17.33	$57.39	$994.57
Resume	236 (75% of Applicants submit resumes)	0.33 (1 every 3 years)	77.88	10/60 (GS-13, Step 6)	12.98	$57.39	$744.92
Optional Application for Federal Employment OF-612	79 (25% of Applicants submits the OF-612)	0.33 (1 every 3 years)	26.07	10/60 (GS-13, Step 6)	4.35	$57.39	$249.65
Confidential Financial Disclosure Form (OGE For 450)	1,410	1 per year	1,410	10/60 (GS-13, Step 6)	235	$57.39	$13,486.65
Subtotal	--	--	1,617.90	--	269.66	--	$15,475.79
OSHA Challenge Program
Challenge Administrators Application	6	1 per year	6	5 hours (GS-13, Step 6)	30	$57.39	$1,721.70
Challenge Candidate Application	12	1 per year	12	10 hour (GS-13, Step 6)	120	$57.39	$6,886.80
Administrators Annual Summary Report	29	1 per year	29	20 (GS-13, Step 6)	580	$57.39	$33,286.20
Subtotal	--	--	47	--	730	--	$41,894.70
Grand Total	--	--	4,672	--	11,332	--	$650,324

Total Cost for federal personnel is $650,324

15. Explain the reasons for any program changes or adjustments.

OSHA is requesting an adjustment decrease of 363 burden hours from 90,863 to 90,500 hours. The decrease is primarily due to the lack of Challenge participation, and lack of training of new SGE applicants and re-approval training of existing SGEs due to the negative impact of the COVID-19 imposed on all OSHA Cooperative Programs.

16. For collections of information whose results will be published, outline plans for tabulation, and publication. Address any complex analytical techniques that will be used. Provide the time schedule for the entire project, including beginning and ending dates of the collection of information, completion of report, publication dates, and other actions.

OSHA will not publish the information collected under these standards.

17. If seeking approval to not display the expiration date for OMB approval of the

information collection, explain the reasons that display would be inappropriate.

OSHA lists current valid control numbers in §§1910.8, 1915.8, 1917.4, 1918.4, and 1926.5 and publishes the expiration date in the Federal Register notice announcing OMB approval of the information collection requirement. (See 5 CFR 1320.3(f)(3)). OSHA believes that this is the most appropriate and accurate mechanism to inform interested parties of these expiration dates.

17. Explain each exception to the certification statement.

OSHA is not seeking such an exception to the certification statement.

B. COLLECTION OF INFORMATION EMPLOYING STATISTICAL METHODS

This Supporting Statement does not contain any collection of information requirements that employ statistical methods.

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